Barangay Piapi vs. Ignacio Talip

Jurisdiction over actions involving title to or possession of real property is determined by the assessed value of the property, not its market value, and the assessed value must be alleged in the complaint. Where the complaint fails to allege the assessed value and instead states only the market value, the court must determine jurisdiction based on the allegations as pleaded, and the action falls within the jurisdiction of the lower court if the value does not exceed the statutory threshold.

The petitioners are a barangay and its individual residents who claimed possession of a 3.2-hectare parcel of land in Piapi, Padada, Davao del Sur, covered by OCT No. P-(3331)-4244 in the name of Juan Jayag. The respondent, Ignacio Talip, represented the heirs of Juan Jayag and had obtained a Transfer Certificate of Title over the same property. The jurisdictional threshold for RTC versus MCTC jurisdiction over real property actions was governed by Section 19(2) of Batas Pambansa Blg. 129, as amended by R.A. No. 7691, which set the threshold at ₱20,000.00 for areas outside Metro Manila.

Petitioners, a barangay and its individual residents, filed a complaint for reconveyance and damages against respondent Ignacio Talip, who represented the heirs of Juan Jayag, before the RTC of Digos, Davao del Sur. The complaint alleged that petitioners and their predecessors-in-interest had been in actual, peaceful, continuous, and open possession for more than 30 years of a 3.2-hectare parcel of land in Piapi, Padada, Davao del Sur, covered by OCT No. P-(3331)-4244 in the name of Juan Jayag, with a market value of ₱15,000.00. The land had been subdivided into lots of approximately 100 square meters each, where individual petitioners built their houses, while the remaining portion was used for the barangay center, multi-purpose gym, and health center. Petitioners alleged that respondent fraudulently obtained a Transfer Certificate of Title in his name, paid real estate taxes in 1998, and threatened to build a barb-wire fence around the land.

Instead of filing an answer, respondent moved to dismiss the complaint on the ground that the RTC had no jurisdiction, citing the assessed value of the land at only ₱6,030.00 and invoking Section 33(3) of BP Blg. 129, as amended by R.A. No. 7691, which confers exclusive original jurisdiction on the Municipal Circuit Trial Court for real property actions where the assessed value does not exceed ₱20,000.00. In their opposition, petitioners alleged that jurisdiction was vested in the RTC because the total assessed value of the property was ₱41,890.00, as shown by a Real Property Field Appraisal and Assessment Sheet dated August 20, 1996 issued by the Provincial Assessor of Davao del Sur.

The trial court dismissed the complaint for lack of jurisdiction, and the motion for reconsideration was denied. The Supreme Court examined the allegations in the complaint and found that petitioners failed to allege the assessed value of the subject property, stating only the market value of ₱15,000.00. The Court noted that the complaint's allegations involved title to or possession of real property, and under the applicable rules, the assessed value of the property, or if there is none, the estimated value thereof, must be alleged by the claimant.

• Jurisdiction of the RTC: Petitioners contended that under Section 19(1) of BP Blg. 129, as amended, the RTC has jurisdiction over the complaint for reconveyance since it is incapable of pecuniary estimation.
• Assessed Value: Petitioners alleged in their opposition to the motion to dismiss that jurisdiction is vested in the RTC because the total assessed value of the property is ₱41,890.00, as shown by a Real Property Field Appraisal and Assessment Sheet dated August 20, 1996 issued by the Provincial Assessor of Davao del Sur.

• Lack of RTC Jurisdiction: Respondent moved to dismiss the complaint on the ground that the RTC has no jurisdiction over the case because the assessed value of the land is only ₱6,030.00, citing Section 33(3) of BP Blg. 129, as amended by R.A. No. 7691, and maintaining that the case falls within the exclusive jurisdiction of the Municipal Circuit Trial Court of Padada-Kiblawan, Davao del Sur.

• Jurisdiction over the Reconveyance Action: Whether the RTC has jurisdiction over the complaint for reconveyance where the complaint alleges only the market value of the property (₱15,000.00) and not its assessed value.

• Jurisdiction over the Reconveyance Action: No. The RTC correctly dismissed the complaint for lack of jurisdiction. The action involves title to real property, and under Section 19(2) of BP Blg. 129, as amended, the RTC exercises exclusive original jurisdiction only where the assessed value of the property exceeds ₱20,000.00. Since the complaint failed to allege the assessed value and stated only the market value of ₱15,000.00, the case falls within the exclusive original jurisdiction of the Municipal Circuit Trial Court under Section 33(3) of the same law.

• Jurisdiction over the Reconveyance Action: The Court applied the principle that the nature of an action is determined not by the caption of the complaint but by the allegations contained therein and the reliefs prayed for. Citing Huguete vs. Embudo, the Court held that where the ultimate objective of the plaintiffs is to obtain title to real property, the action should be filed in the proper court having jurisdiction over the assessed value of the property subject thereof. The Court examined the allegations in the complaint and found that it involved title to, or possession of, real property. However, the petitioners failed to allege the assessed value of the subject property, stating instead only the market value of ₱15,000.00. Under Section 19(2) of BP Blg. 129, as amended, the RTC exercises exclusive original jurisdiction in civil actions involving title to or possession of real property where the assessed value exceeds ₱20,000.00. Since the complaint did not allege the assessed value and the market value stated was ₱15,000.00, the Court concluded that the Municipal Circuit Trial Court of Padada-Kiblawan, Davao del Sur, not the RTC, has jurisdiction over the case pursuant to Section 33(3) of BP Blg. 129, as amended by R.A. No. 7691. The Court also cited Section 7(b), Rule 141 of the Revised Rules of Court, which requires that the assessed value of the property, or if there is none, the estimated value thereof, shall be alleged by the claimant.

• Determination of Jurisdiction by Allegations of the Complaint — The nature of an action, as well as which court or body has jurisdiction over it, is determined based on the allegations contained in the complaint of the plaintiff, irrespective of whether or not the plaintiff is entitled to recover upon all or some of the claims asserted therein. The Court applied this principle to hold that the complaint for reconveyance, which sought title to real property, must be filed in the court having jurisdiction over the assessed value of the property.
• Jurisdiction over Real Property Actions Based on Assessed Value — Under Section 19(2) of BP Blg. 129, as amended, the RTC exercises exclusive original jurisdiction over civil actions involving title to or possession of real property where the assessed value exceeds ₱20,000.00 (or ₱50,000.00 in Metro Manila). Under Section 33(3) of the same law, the MCTC exercises exclusive original jurisdiction where the assessed value does not exceed ₱20,000.00 (or ₱50,000.00 in Metro Manila). The Court held that the complaint's failure to allege the assessed value, stating only the market value, resulted in the case falling within MCTC jurisdiction.

• "the nature of an action is not determined by what is stated in the caption of the complaint but by the allegations of the complaint and the reliefs prayed for. Where the ultimate objective of the plaintiffs, like petitioners herein, is to obtain title to real property, it should be filed in the proper court having jurisdiction over the assessed value of the property subject thereof." — This passage, quoted from Huguete vs. Embudo, states the controlling principle for determining jurisdiction over actions involving title to real property and is the ratio decidendi of the case.
• "The Rule requires that 'the assessed value of the property, or if there is none, the estimated value thereof, shall be alleged by the claimant.'" — This excerpt cites Section 7(b), Rule 141 of the Revised Rules of Court, establishing the pleading requirement that the claimant must allege the assessed value of the property in actions involving title to real property.

• Huguete vs. Embudo, G.R. No. 149554, July 1, 2003, 405 SCRA 273 — Controlling precedent, followed by the Court. The case established that where the ultimate objective of the plaintiffs is to obtain title to real property, the action should be filed in the proper court having jurisdiction over the assessed value of the property.
• Dimo Realty & Development Inc. vs. Dimaculangan, G.R. No. 130991, March 11, 2004, 425 SCRA 376 — Cited for the hornbook principle that the nature of an action and which court has jurisdiction over it is determined based on the allegations in the complaint.
• Intestate Estate of Alexander T. Ty vs. Court of Appeals, 356 SCRA 661 (2001) — Cited in Dimo Realty for the same principle regarding determination of jurisdiction by the allegations of the complaint.
• Serrano vs. Delica, G.R. No. 136325, July 29, 2005 — Cited for the rule under Section 7(b), Rule 141 of the Revised Rules of Court requiring the assessed value of the property to be alleged by the claimant.

• Section 19(2), Batas Pambansa Blg. 129, as amended — Provides that RTCs shall exercise exclusive original jurisdiction in all civil actions which involve the title to, or possession of, real property, or any interest thereon, where the assessed value of the property involved exceeds ₱20,000.00, or for civil actions in Metro Manila, where such value exceeds ₱50,000.00. The Court applied this provision to determine that the RTC lacked jurisdiction because the complaint did not allege an assessed value exceeding the threshold.
• Section 33(3), Batas Pambansa Blg. 129, as amended by R.A. No. 7691 — Provides that MTCs, MTs, and MCTCs shall exercise exclusive original jurisdiction in all civil actions which involve title to, or possession of, real property where the assessed value does not exceed ₱20,000.00, or in Metro Manila, where such value does not exceed ₱50,000.00. The Court applied this provision to conclude that the Municipal Circuit Trial Court of Padada-Kiblawan, Davao del Sur has jurisdiction over the case.
• Section 7(b), Rule 141, Revised Rules of Court — Requires that the assessed value of the property, or if there is none, the estimated value thereof, shall be alleged by the claimant. The Court cited this rule to emphasize that petitioners failed to comply with the pleading requirement.

Panganiban, J. (Acting Chief Justice, Chairman), Corona, J., Carpio-Morales, J., and Garcia, J. concurred in the decision.